Comments on “A Marine Reserve for Great Barrier
Island?”the Seafood Industry Council of New Zealand
by Nici Gibbs, Policy Manager SeaFIC
22 July 2003

Thank you for the opportunity to comment on the discussion document
and questionnaire on the Department of Conservation’s proposal for a marine
reserve on the north-east coast of Great Barrier Island.

IntroductionThe New Zealand Seafood Industry Council Ltd (SeaFIC) is the primary
umbrella organisation representing the generic interests of all sectors
of the New Zealand seafood industry, a sector that includes fishers, marine
farmers, seafood processors, wholesalers, retailers, and exporters. SeaFIC
is owned by 27 shareholders – each of which represents a particular sector
of the seafood industry. Our shareholders collectively represent around
94% of the seafood industry by value.
You will be aware that the seafood industry’s interest in marine reserves
is significant. The well-being of the marine environment is fundamental
to the industry’s economic, social and environmental contribution to New
Zealand. The seafood industry is also a major rights holder and user of
resources in the marine environment. Secure rights of access to the marine
environment underpin the industry’s contribution and are also fundamental
to protecting the integrity of New Zealand’s fisheries management regime.
The industry acknowledges that marine reserves have a role to play
as one of several available tools for managing the marine environment.
Because marine reserves can have significant economic and social impacts
on sustainable extractive uses, we are interested in ensuring that marine
reserves are established only where analysis demonstrates that:

a marine reserve is the best management tool for achieving the identified
protection objectives; and

the benefits of having a marine reserve outweigh the costs, and any costs
on existing uses and values can be avoided, remedied or mitigated.

As SeaFIC’s interest in marine reserves and the protection of marine biodiversity
is generic rather than specific, we will not be responding to the specific
questions in your questionnaire. Instead, we take this opportunity to comment
on the discussion document and provide an indication of the type of information
and analysis that we would expect to be included in a formal application
for a marine reserve at Great Barrier Island, should it be decided to pursue
such a course.

General comments on the discussion documentSeaFIC considers that A Marine Reserve for Great Barrier Island?
is an overly simplified document that does not provide readers with the
necessary factual information or analysis to make an informed judgement
on the merit of the proposed reserve. General claims are made about fishing
impacts and about the benefits of the proposed reserve but no supporting
material is presented or cited. Standard concepts fundamental to the protection
of marine biodiversity are misrepresented and misused in support of the
creation of a reserve (see below for more detailed comments). The discussion
paper proposes to exclude fishing from a large area because of its perceived
impacts on ecological values, but neither the ecological values of the
area nor the alleged fishing impacts are properly assessed and described.

From the fishing industry’s point of view, this situation is far from
satisfactory, given the importance of issues such as potential loss of
access to marine resources. We understand that this document is only a
discussion paper and that a formal marine reserve application may be developed
at a later stage. However, this discussion paper is still part of a community
consultation process and should provide sufficient and relevant information.
It is of particular concern to SeaFIC that ill-informed comments on the
discussion paper may be used in developing the formal marine reserve application
by the Department of Conservation.

We also recognise that information to justify scientifically the establishment,
location and size of a marine reserve is usually sparse and expensive to
collect. However, an up-front approach which acknowledges the lack of information
would be preferable to the use of unconvincing and unsupported generalisations.
A pragmatic and consultative approach, rather than a reliance on feel-good
statements and unsupported assertions of benefit, would do more to increase
stakeholders’ confidence and give them incentive to contribute to the process.

Purpose of the marine reserve – scientific study or
biodiversity protection?The discussion document contains confused messages about the proposed
purpose of the marine reserve. If the reserve is to be established under
the existing legislation (the Marine Reserves Act 1971), then it must be
“for the purpose of preserving… for the scientific study of marine life,
areas of New Zealand that contain underwater scenery, natural features,
or marine life, of such distinctive quality, or so typical, or beautiful,
or unique, that their continued preservation is in the national interest”.
However, the document contains little information on the proposed scientific
study programme for the area, or explanation of why a marine reserve is
required to facilitate any such study.

Recommendation: If a formal application
proceeds under existing legislation, further justification of how the proposed
reserve will contribute to scientific study of marine life is required.

Rather than focusing on the merits of the area for scientific study, the
document focuses on some of the concepts underpinning the use of marine
reserves to protect biodiversity – specifically, the concepts of “networks”
of protected areas and “representativeness”. These concepts have
been established over the past decade and are extensively described in
the national and international literature advocating marine reserves for
biodiversity protection purposes. The discussion document misrepresents
these concepts in several important respects.

Protection targetsThe document refers in several places to the New Zealand Biodiversity
Strategy (Objective 3.6, action point b) which is “to achieve a target
of protecting 10% of New Zealand’s marine environment by 2010 in view of
establishing a network of representative protected marine areas”. The
Biodiversity Strategy makes it clear that this objective is to be achieved
through a range of mechanisms, not just marine reserves [1] .
This multi-mechanism approach to achieve the protection target is contrary
to the approach implied on page 9 of the discussion document, which misrepresents
the level of protection currently existing in the marine environment by
counting only the areas covered by marine reserves.

Regardless of the justification or otherwise of having a 10% protection
target, SeaFIC is aware that there is a lack of public understanding of
how a 10% target might be implemented, with many people holding the mistaken
view that marine reserves are the only available protection mechanism.
It is disappointing to see this misconception reflected in a government
discussion document.

Recommendation: Clarify that the
Biodiversity Strategy protection target is intended to be achieved through
a range of mechanisms including, but not limited to, marine reserves.If
the Biodiversity Strategy is to be used as part of the reasoning for establishing
a marine reserve, it follows that the application should contain an analysis
of why a marine reserve is the most appropriate tool to achieve the protection
objectives, and how the specific marine reserve will contribute to the
“network of representative areas” (see further comments below).

[1] See for instance, Objective 3.6: Protect a full range
of natural marine habitats and ecosystems to effectively conserve marine
biodiversity, using a range of appropriate mechanisms, including legal
protection; and Action a) Develop and implement a strategy for establishing
a network of areas that protect marine biodiversity, including marine reserves,
world heritage sites, and other coastal and marine management tools such
as mataitai and taiapure areas, marine area closures, seasonal closures
and area closures to certain fishing methods.

Networks of marine protected areasPage 4 of the document implies that the proposed reserve will contribute
to a “network of marine protected areas” and that this network will
provide “a series of safe havens within movement range of adults or
juveniles”. However, no information is provided on the overall plan
for the “network” and how it might be established. If this network is to
truly provide safe havens for species moving between reserves, or to boost
populations through source-and-sink mechanisms as is referred to on page
5, its design would require much more information and sophisticated procedures
to select and design marine reserves than the ones described in the discussion
paper.
A network does not simply mean “more than one marine reserve”. It implies
a significant degree of analysis and planning according to pre-determined
criteria and with overarching objectives as to what the network is intended
to achieve. There is no evidence that the proposed marine reserve location
has been selected on the basis of characteristics usually required for
establishing a network (eg., functional connectivity, representativeness
at regional and national scales).

Recommendation: Provide further
information on the “network” that the proposed marine reserve is intended
to contribute to, and the manner in which that contribution will be achieved.

RepresentativenessThe term ‘representative marine habitats’ is used in the document (eg.,
page 4) but is not explained. Further, the statement (page 8) relating
to some habitats in the proposed reserve being of particular interest because
they are not ‘represented’ in marine reserves elsewhere indicates some
confusion between representativeness and comprehensiveness, two of the
fundamental concepts underpinning the design of marine reserve networks.
The definitions of representativeness and comprehensiveness are as follow:

Comprehensiveness: a national network of reserves should include the full
range of ecosystems identified nationally; and

Representativeness: individual reserves should reflect the biodiversity
of the ecosystem they come from.

Without some form of classification of the marine environment and some
identification, even preliminary, of the full range of ecosystems in New
Zealand waters, it is difficult to know what the Great Barrier Island marine
reserve may be representative of. In any case, representativeness is not
mentioned in the Marine Reserve Act 1971 which refers only to the protection
of ‘typical’, ‘beautiful’ or ‘unique’ characteristics of the area.

Recommendation: Clarify why, and
of what, the proposed marine reserve is representative.

Site selectionThe discussion document does not describe how the area proposed for
the reserve was selected nor the criteria for site selection. For example,
have only ecological criteria been considered or have socio-economic criteria
also been taken into account, and how? In the absence of such information,
it appears that the Great Barrier Island marine reserve site has been selected
in an ad hoc and opportunistic manner. This goes against international
trends aiming at developing national networks of representative marine
reserves and thus avoiding the well known ‘hot spot’ syndrome. The ‘hot
spot’ syndrome is well illustrated in the discussion paper by the way ecological
values are described (pages 8, 10-13) – ie., listing broad geomorphological
areas (eg. estuarine, beach, reefs, sediment areas) that the reserve will
cover, listing iconic species, and giving snap-shots of some selected habitats.
Sentimental and emotive statements about the spectacular beauty of marine
habitats and communities do not alleviate the need for factual information
on, and proper analysis of the ecological importance of, and threats to,
the area proposed for a marine reserve.

Recommendation: Provide further
information on the criteria and rationale for site selection, and an analysis
of alternative sites.

Marine reserves and fisheries managementThroughout the discussion paper, fishing is repeatedly presented as
the main cause of impact in the area of interest and the main reason for
the creation of the marine reserve (see objective 4, page 15). The paper
asserts that fisheries rules do not protect the large and old marine animals
(page 5). There is reference to local residents’ perceptions that “fish
aren’t as plentiful as they used to be in the ‘old days’” (page 3,
4) and a statement about marine reserves helping “rebuild depleted stocks
of snapper, crayfish and other species” (page 5). A claim is also made
on page 6 that “fishing is likely to improve in areas near the reserve
and, in the long term, may benefit fish stocks further afield”.

However, the document does not provide any information or references
to support these claims. SeaFIC is particularly concerned about the misleading
and unreferenced statements contained in the discussion document concerning
the alleged fisheries management benefits of marine reserves.

Literature reviewsWe draw your attention to a recent study undertaken by the Australian
Bureau of Rural Sciences and CSIRO 2 . The authors of this study undertook
an extensive review of the international scientific literature on the effectiveness
of marine reserves for fisheries management purposes. The review focuses
on the effectiveness of marine sanctuaries/no-take areas that have been
established specifically for fisheries management purposes, documenting
potential and realised benefits for fisheries.

The authors note that there are few well documented examples of no-take
reserves being used as part of fisheries management. While there is reasonable
evidence of benefits inside reserves (eg., increase in fish abundance)
in the literature, there is virtually no empirical evidence for the key
benefits outside reserves (spillover, larval export, stability of fisheries
production). Further, the majority of studies into fish abundance concentrate
on large coral reef predatory fish, which are the most targeted species
in tropical fisheries and the most severely affected by fishing (because
of their slow growth rate, low reproductive rate and territorial behaviour).
Much less is known about the effect of marine reserves on other ecosystems
(e.g. continental shelf, open oceans).

The study referred to above also notes that experiences of tangible
fisheries benefits outside marine reserves are often limited to either
the recovery of highly depleted stocks or to subsistence-scale tropical
reef fisheries under little formal management. There is little documented
evidence that no-take reserves improve fisheries yield in fisheries already
under tight management controls such as those imposed by New Zealand’s
Quota Management System. The study also notes that marine reserves have
the potential to significantly reduce net benefits for commercial fisheries
and concludes that “there are no well-documented examples where marine
fishery sanctuaries have been shown to provide and maintain net economic
benefits for previously existing fisheries” (Ward et al. 2001 [2]).
This is an increasing concern if large reserves in both inshore and offshore
areas are to be created.

The authors conclude that it is difficult to assess whether no-take
marine reserves are useful tools for fisheries management because there
are few such reserves worldwide. At present, much of the evidence of fisheries
benefits that is used to promote marine reserves for fisheries management
purposes is largely theoretical and circumstantial.

As Holland (2002) notes, there are serious limitations to our ability to
address these issues with empirical research. Doing so rigorously would
require a number of replications over long periods with comparisons to
controls, and even then might only provide conclusions valid for very specific
sets of circumstances. The full impacts of reserves can take many years
to be realised and will be confounded by environmental and
regulatory changes.

Modelling studies provide an alternative approach to evaluate basic
questions about how reserves of various designs in various environments
might affect fisheries. Several published modelling studies of marine reserves
and closed areas for fisheries suggest that a correctly sized marine reserve
may increase yields in fisheries that are subject to growth or recruitment
overfishing, but that little if any yield increases can be achieved in
fisheries where effort is already at the level that produces maximum sustainable
yield or maximum yield per recruit (e.g., Beverton and Holt 1957, Guénette
and Pitcher 1999, Hannesson 1998 and 2002, Hastings and Botsford 1999,
Holland and Brazee 1996, Nowlis and Roberts 1999, Polacheck 1990, Rodwell
et al. 2002, Sanchirico and Wilen 1998, 1999 and 2002, Smith and Wilen
2003).

[2] Ward, T J, Heinemann D, & Evans, N (2001). The
role of marine reserves as fisheries management tools: A review of concepts,
evidence and international experience. Bureau of Rural Sciences, 184pp.
This report can be viewed or downloaded from www.affa.gov.au/corporate_docs/publications/pdf/rural_science/fisheries/brs_marine_report.pdf
(84 pages, 770KB). The authors are not impartial in their research, having
consulted mainly the pro-marine reserves literature. They also made the
mistake of inventing yet another unproven model to derive perceived fisheries-related
benefits from.

Closures for fisheries management purposesFisheries agencies worldwide have long used area closures as part of
fisheries management. However, the principles governing fisheries and conservation
approaches to using spatial closures differ significantly and, at times,
may conflict with each other. Optimal designs for area closure differ between
areas closed for biodiversity protection and areas closed for fisheries
management purposes. Areas closed for fisheries management purposes are
normally designed to benefit a limited number of target species, which
requires detailed knowledge of the species spawning and dispersal behaviour.
By comparison, biodiversity protection MPAs aim to protect whole ecosystems
and are designed according to the concept of representativeness.

Recommendation: If a formal application
is to proceed, it should provide detail (through the use where possible
of published research) of the fisheries that operate in the area, the types
of gear being used, and the nature and extent of any impact on ecological
values. If fishing impacts are identified, then it needs to be assessed
whether a marine reserve is the best tool to address these impacts, or
whether fisheries management tools are more appropriate.Any claims of fisheries
management benefits arising from the establishment of a marine reserve
should be justified with reference to:

Size of the proposed reserve & fisheries management implicationsIn the section ‘Does size matter?’ (page 9), the paper rightly says
that the best size for a marine reserve depends on what is being protected.
However, the paper then goes on to say that a large marine reserve is preferable
in order to minimise fishing impact (the so-called ‘edge effect’). Thus,
the need for the large size of the Great Barrier Island reserve is justified
by a perception of fishing impacts, but without providing any information
on how these presumed impacts affect the communities and species to be
protected.
We also note that the claim that “fishing is likely to improve in
areas near the reserve” (page 6) contradicts the later discussion on
the relation between the size of the reserve and the ‘edge effect’ (page
9). In fact, the ‘edge effect’ is a much desired effect when expecting
fisheries benefits (then referred to as ‘spill-over’).

Objectives and marine reserve management

Establishing clear objectivesThe objectives of the Great Barrier Island marine reserve listed on
page 15 are very generic and it is unclear how they relate to the specific
features of the proposed reserve. There is also confusion between objectives
and benefits (outcomes) as shown in the paragraph ‘What are the benefits’
(page 5). The repeatedly stated goal of protecting the marine environment
for the benefits of present and future generations is too generic to be
of any relevance. Generic goals need to be translated into clear objectives
at the local level, based on analysis of the ecological values that require
protection, and assessment of any threats they may be under. Without clearly
defined objectives and measurable outcomes it will be difficult to assess
whether or not the proposed reserve is effectively protecting biodiversity.

Recommendation: Develop clear
objectives and outcomes that reflect both the specific values that require
protection in the proposed marine reserve, and the identified threats to
those values.

Management strategy and planningThe document does not describe any management strategy once the marine
reserve has been declared. There are no details on any monitoring programme
or enforcement plans. The declaration of a marine reserve may eventually
fail as a marine resource management and protection tool if its performance
is not monitored. Scientists often warn that it will be difficult to assess
the performance of marine reserves without carefully designed monitoring
plans. With regard to enforcement, it appears that, and as observed for
many marine reserves elsewhere, managers optimistically rely on community
support and involvement to ensure compliance with regulations (page 7).
It remains to be demonstrated whether such community support exists and/or
is capable of ensuring compliance in practice.

Recommendation: If a formal application
proceeds, the application should include a clear management strategy to
achieve the identified objectives and outcomes of the proposed reserve,
and a monitoring programme to evaluate whether the reserve objectives are
being met.

Assessing potential impacts of the marine reserveThe section ‘Uses of the north-east coast’ (page 6) does not
provide sufficient details on current commercial and non-commercial uses
in the area proposed for the reserve or how important these uses are to
stakeholder groups and the local community. It is stated in the next section
‘How would a marine reserve affect you’ (page 6) that ‘a marine
reserve on the north-east coast may have economic and social implications
for commercial and recreational fishers in the area’, but no analysis of
these implications is presented. In the case of fishing, it is now well
documented that marine reserves can have adverse biological and socio-economic
effects through displacement of fishers and concentration of fishing effort
in non-reserved areas. Except in the case of tangata whenua (page 7), there
is no indication of any mechanisms to mitigate impacts and accommodate
users’ needs.
SeaFIC considers that, given the potential impacts of marine reserves,
all marine reserve proposals should undergo an assessment of their costs
and benefits so as to ensure that the non-extractive benefits of a system
of marine reserves are achieved effectively and efficiently and that marine
reserves do not compromise or interfere with other marine management systems
already in place. In general, a benefit-cost analysis should attempt to
determine whether the proposed reserve provides greater net benefits than
some alternative policy. The basis for comparison might be the status quo
or might include alternative policies designed to achieve similar objectives.
Quantification and valuation of costs and benefits from a marine reserve
is likely to be difficult and imprecise due to uncertainty about the direct
and indirect impacts of a reserve and of what would happen in the absence
of a reserve. However, the difficulty of this task should not be used as
an excuse to avoid it completely.
A complete economic evaluation of a marine reserve should also explore
the probable distribution of benefits and costs. Even if a marine reserve
does have positive net benefits overall, it is likely to disadvantage some
individuals and groups. Compensation of losers in some form may be necessary
or advisable to ensure the acceptance and success of the marine reserve.
Marine reserves perceived as unfairly imposed are likely to require higher
compliance costs and may generate political action that will block the
creation of a reserve or lead to its failure or repeal.

Recommendation: Any formal application
should contain:(a) details on the social and economic impacts
of the proposed reserve on existing uses and values, and contain measures
to avoid, remedy or mitigate any such impacts; and(b) an analysis of the costs and benefits of
the proposal.

Other mattersThe lack, throughout the paper, of referenced information and details
of data sources, scientific and non-scientific, is of serious concern.
There are references to ‘New discoveries’ (page 3), to a recent
study at Leigh Marine Reserve (page 9), to surveys (page 10),
to ‘site survey and investigations’ (page 14), but none are properly
referenced.

Recommendation: Include references
for all information referred to in the document.